EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE 

PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: James A. Tompkins 703-305-5697

Monsanto Company

PP-0F7741

EPA has received a pesticide petition (PP-0F7741) from Monsanto Company, 

1300 I St., NW., Suite 450 East, Washington DC 20052 proposing, pursuant to section 

408(d) of the Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. 346a(d), to 

amend 40 CFR part 180.364 by establishing a tolerance for residues of glyphosate N-

(phosphonomethyl) glycine in or on the raw agricultural commodity corn, field, forage at 

13 parts per million (ppm) to support the use of glyphosate in RHS seed corn production. 

EPA has determined that the petition contains data or information regarding the elements 

set forth in section 408 (d)(2) of FDDCA; however, EPA has not fully evaluated the 

sufficiency of the submitted data at this time or whether the data supports granting of the 

petition. Additional data may be needed before EPA rules on the petition.

A. Residue Chemistry

1. Plant metabolism. The qualitative nature of glyphosate residues in plants and 

livestock is adequately understood. The terminal residue to be regulated in nontransgenic 

plants and transgenic crops modified to express the Agrobacterium sp. EPSPS and 

oxireductase genes is glyphosate per se. For crops (currently soybeans and corn) that 

have a transgenic variety engineered to express the microbial glyphosate acetyltransferase 

gene (gat4601), the combined residues to be regulated are glyphosate and N-acetylglyphosate. The qualitative nature of the glyphosate residue will not be changed as a 

result of the proposed tolerance changes. Glyphosate herbicides are not applied directly 

to livestock, so the only potential exposure is via glyphosate residues in their diet. On 

December 3, 2008, EPA published a final rule (EPA-HQ-OPP-2007-0147; FRL-8385-7) 

amending section 180.364 to reflect that the terminal residue to be regulated in livestock 

(and in soybean commodities and grain aspirated fractions) is glyphosate and its 

metabolite N -acetyl-glyphosate, expressed as glyphosate.

2. Analytical method. Adequate enforcement methods are available for analysis of 

residues of glyphosate and its metabolite AMPA in or on plant and livestock 

commodities. These methods include gas liquid chromatography (GLC), Method I in 

Pesticides Analytical Manual (PAM) II (0.05 ppm limit of detection), and High 

Performance Liquid Chromatography (HPLC) with fluorometric detection (0.0005 ppm 

limit of detection). Use of the GLC method is discouraged due to the lengthiness of the 

experimental procedure. The HPLC procedure has undergone successful Agency 

validation and was recommended for inclusion in PAM II. A gas chromatography/mass 

spectrometry (GC/MS) method for glyphosate in crops has also been validated by EPA’s 
2

Analytical Chemistry Laboratory (ACL). Thus, adequate analytical methods are 

available for residue data collection and enforcement of the proposed tolerances for 

glyphosate.

3. Magnitude of residues. Residue data submitted with this petition support the 

proposed tolerances for the agricultural commodities corn, field, forage at 13 ppm, to 

support the use of glyphosate in RHS seed corn production. Any secondary residues 

occurring in livestock commodities will be covered by existing tolerances.

B. Toxicological Profile

The existing toxicity database for glyphosate is complete, with the exception of an 

immunotoxicity study, which only recently became a requirement for pesticides under 40 

CFR Part 158 (see section 9 following). There is high confidence in the quality of the 

existing studies and the reliability of the toxicity endpoints identified for use in risk 

assessment. EPA has considered available information regarding the variability of the 

sensitivities of major identifiable subgroups of consumers, including infants and children. 

1. Acute toxicity. The nature of the acute toxic effects caused by glyphosate has

been evaluated by the Agency. Glyphosate is of low acute toxicity by oral, dermal, and

ocular routes of exposure, as all studies are in Toxicity Category III or IV. Acute oral 

toxicity of glyphosate in the rat and dermal toxicity in the rabbit are both greater than 

5000 mg/kg (Toxicity Category IV) and any corneal opacity or irritation caused by 

glyphosate is temporary and clears up in 7 or less days (Toxicity Category III). 

Glyphosate is a mild skin irritant (Toxicity Category IV) and is not a dermal sensitizer. 

The acute inhalation study for glyphosate was waived due to glyphosate being a 

nonvolatile solid. An acute dietary endpoint for use in human health risk assessments was 

not selected for the general population, since an appropriate endpoint attributable to a 

single exposure was not identified in the toxicology data base.

Table 1 Acute Toxicity Profile - Test Substance 

Guideline 

No. Study Type MRID(s) Results Toxicity Category

870.1100 Acute oral 41400601 LD50 > 5,000 mg/kg IV

870.1200 Acute dermal 41400602 LD50 > 5,000 mg/kg IV

870.1300 Acute inhalation None

The requirement for an 

acute inhalation LC50

study was waived

None

870.2400 Acute eye irritation 41400603

Corneal opacity or 

irritation clearing in 7 

days or less

III

870.2500 Acute dermal irritation 41400604 Mild or slight irritant IV
3

Table 1 Acute Toxicity Profile - Test Substance 

870.2600 Skin sensitization 00137138 Not a sensitizer None

]

2. Genotoxicity. In vitro and in vivo genotoxicity studies have been conducted 

with glyphosate. Short term assays for genotoxicity consisting of a bacterial reverse 

mutation assay (Ames test), an in vitro assay for cytogenetic damage using Chinese 

hamster ovary cells, and in vivo cytogenic assay in rat bone marrow have been conducted 

on glyphosate. These studies all show a lack of genotoxicity.

Table 2 Genotoxicity Profile 

Guideline No./ Study 

Type

Results

Gene Mutation

870.5265

Non-mutagenic when tested up to 1000 ug/plate, in presence and 

absence of activation in S. typhimurium strains TA98, TA100, 

TA1535 and TA1537.

Gene Mutation

870.5300

Non-mutagenic at the HGPRT locus in Chinese hamster ovary cells 

tested up to cytotoxic concentrations or limit of solubility, in 

presence and absence of activation.

In Vivo Cytogenetics -

Bone Marrow 870.5385

Non-mutagenic in rat bone marrow chromosome assay up to 1000 

mg/kg in both sexes of Sprague Dawley rats.

870.5550

Rec - Assay and Gene 

Mutation Assay 

There was no evidence of recombination in the rec-assay up to 

2,000 ug/disk with B. subtilis H17 (rec+) and M45 (rec-). Negative 

for reverse gene mutation, both with and without S-9, up to 5,000 

ug/plate (or cytotoxicity) with E.coli SP2hcrA and S. typhimuarium

TA98, TA100, TA1535, TA1537, and TA1538.

]

3. Reproductive and developmental toxicity. Developmental studies in rats and 

rabbits were conducted with glyphosate. In rabbits, a maternal NOAEL of 175 mg/kg/day 

was determined based on mortality, diarrhea, and nasal discharge at the LOAEL of 350 

mg/kg/day. This was the lowest NOAEL of all major studies. The developmental 

NOAEL was 350 mg/kg/day (HDT).

In rats, developmental effects of unossified sternebrae and decreased fetal body weight 

were observed at a LOAEL of 3500 mg/kg/day (HDT) which was also the LOAEL for 

maternal toxicity. The maternal NOAEL was 1,000 mg/kg/day based on mortality, 

decreased body weight gain, inactivity, red matting on nose, mouth, forelimbs, and head, 

decrease in total implantations/dam and nonviable fetuses/dam. The developmental 

NOAEL in rats was 1000 mg/kg/day. 
4

No reproductive effects were observed in the multigeneration study and in the 2-

generation rat reproduction study, the offspring and parental NOAELs were 500 

mg/kg/day based on decreased pup body weight during lactation (offspring) and soft 

stools, decreased body weight and food consumption (parents) at the LOAEL of 1500 

mg/kg/day. The reproductive NOAEL was greater than or equal to 1500 mg/kg/day 

(HDT).

In developmental studies in rats and rabbits and reproductive findings in rates, 

developmental effects were only observed at maternally toxic doses. There was no 

evidence of any increased susceptibility of the young to the effects of glyphosate in 

developmental and reproductive toxicity studies in rats or rabbits.

A developmental neurotoxicity study was not required.

Table 3 Reproductive and Developmental Toxicity Profile

Guideline No./ Study 

Type

Results

870.3700a

Prenatal developmental 

in rodents (Rat)

Maternal NOAEL = 1000 mg/kg/day

LOAEL = 3500 mg/kg/day based on reduced activity, mortality, 

and reduced body weight gain.

Developmental NOAEL = 1000 mg/kg/day

LOAEL = 3500 mg/kg/day based on increased incidence in the 

number of fetuses and litters with unossified sternebrae and 

decreased fetal body weight.

870.3700b

Prenatal developmental 

in (Rabbit)

Maternal NOAEL = 175 mg/kg/day

LOAEL = 350 mg/kg/day (HDT) based on mortality, diarrhea, soft 

stools, and nasal discharge.

Developmental NOAEL = 350 mg/kg/day (HDT)

LOAEL = not established.

870.3800

Reproduction and 

fertility effects, 

2-generation (Rat)

Parental/Systemic NOAEL = 500 mg/kg/day in males and females

LOAEL = 1500 mg/kg/day (HDT) in males and females based on 

soft stools, decreased body weight gain and food consumption. 

Reproductive NOAEL 1500 mg/kg/day (HDT) in males and 

females

Offspring NOAEL = 500 mg/kg/day (HDT) in males and females

LOAEL = 1500 mg/kg/day in males and females based on 

decreased body weight gain during lactation.

]

4. Subchronic toxicity. In rodent feeding studies, glyphosate showed a NOAEL of 

500 mg/kg/day in a 90-day mouse study and 1445 mg/kg/day (HDT) in a 90-day rat 

study. In a 21/28-day rabbit dermal toxicity study the NOAEL was 1000 mg/kg/day and 
5

the LOAEL was 5000 mg/kg/day based on slight erythema and edema on intact and 

abraded skin of both sexes. 

Table 4 Subchronic Toxicity Profile

Guideline No./ Study 

Type

Results

870.3100

90-Day oral toxicity 

(Mouse)

NOAEL = 500 mg/kg/day in males and females

LOAEL = 2500 mg/kg/day (HDT) in males and females based on 

decreased body weight gains.

870.3100

90-Day oral toxicity 

(Rat)

NOAEL = 1445 mg/kg/day (HDT)

LOAEL = not established

870.3200

21/28-Day dermal 

toxicity (Rabbit)

NOAEL = 1000 mg/kg/day in males and females

LOAEL = 5000 mg/kg/day based on slight erythema and edema on 

intact and abraded skin of both sexes.

]

5. Chronic toxicity. A chronic toxicity study in dogs showed no systemic effects 

found for all examined parameters in males and females at the highest dose tested, 500 

mg/kg/day. Chronic feeding/carcinogenicity studies have been conducted in rodents with

glyphosate and results show no evidence of carcinogenicity in mice or rats. In the mouse, 

a NOAEL of 750 mg/kg/day in males and females was established based on significant 

decreased body weight gain in both sexes and hepatocyte necrosis in males at the LOAEL 

of 4500 mg/kg/day. In the rat, a NOAEL of 362 mg/kg/day in males and 447 mg/kg/day 

in females based on decreased body weight gain in females and increased incidence of 

cataracts and lens abnormalities in males at te LOAEL of 940 mg/kg/day in males and 

1183 mg/kg/day in females. Glyphosate has been classified as “a Group E” 

carcinogen—no evidence of carcinogenicity to humans—based on the absence of 

carcinogenicity in mice and rats.

Table 5 Chronic Toxicity Profile

Guideline No./ Study 

Type

Results

870.4100b

Chronic toxicity (dog)

NOAEL = > 500 mg/kg/day in males and females (HDT)

LOAEL = not established.

870.4300

Carcinogenicity

(Mice)

NOAEL = 750 mg/kg/day in males and females

LOAEL = 4500 mg/kg/day in males and females based on 

significant decreased body weight gain in both sexes and 

hepatocyte necrosis in females.

No evidence of carcinogenicity
6

Table 5 Chronic Toxicity Profile

Guideline No./ Study 

Type

Results

870.4300

Chronic/Carcinogenicity (Rat)

NOAEL = 362 mg/kg/day in males, 447 mg/kg/day in females

LOAEL = 940 mg/kg/day in males, 1183 mg/kg/day in females 

based on decreased body weight gain in females, increased 

incidence of cataracts and lens abnormalities in males.

No evidence of carcinogenicity

]

6. Animal metabolism. In the rat metabolism study, absorption was estimated to 

be 30-36% in males and females. Glyphosate was excreted unchanged in the feces and 

urine (97.5% minimum). The only metabolite present in the excreta was small amounts of 

AMPA. Less than 1% of the absorbed dose remained in the carcass, primarily the bone. 

Repeated dosing did not alter metabolism, distribution, and excretion.

7. Metabolite toxicology. The residue of concern for risk assessment purposes is 

glyphosate per se. The metabolite AMPA is not included in either the tolerance 

expression or the risk assessment. In a meeting of the HED Metabolism Committee held 

8/19/92, the Committee determined that, based on toxicological considerations, AMPA 

need not be regulated and should be dropped from the tolerance expression (Memo, R. 

Perfetti, 10/10/92). Furthermore, in a meeting of the HED Metabolism Committee held 

3/17/94, the Committee discussed whether uses that result in significantly higher residues 

of AMPA in plants and livestock commodities in the future would require that AMPA be 

reintroduced into the tolerance expression of glyphosate. The Committee determined 

that, based on toxicological considerations, AMPA need not be regulated regardless of 

levels observed in foods or feeds (Memo, R. Perfetti, 3/17/94).

8. Endocrine disruption. EPA is required under the FFDCA, as amended by 

FQPA, to develop a screening program to determine whether certain substances 

(including all pesticide active and other ingredients) “may have an effect in humans that 

is similar to an effect produced by a naturally occurring estrogen, or other such endocrine 

effects as the Administrator may designate.” Following recommendations of its 

Endocrine Disruptor and Testing Advisory Committee (EDSTAC), EPA determined that 

there was a scientific basis for including, as part of the program, the androgen and thyroid 

hormone systems, in addition to the estrogen hormone system. EPA also adopted 

EDSTAC’s recommendation that the Program also include evaluations of potential 

effects in wildlife. 

Glyphosate is on the EPA list of the initial 67 pesticide active ingredients and pesticide 

inert high production volume chemicals to be screened under the first phase of EPA’s 

Endocrine Disruption Screening Program (EDSP). This is not a list of “endocrine

disruptors” or “potential endocrine disruptors;” it is simply a list of chemicals to be the 

first to go through EPA’s evaluation process. The process that EPA used to prioritize 

substances for screening did not include a determination of potential endocrine activity of 
7

any of the substances, but rather the potential for exposure. Glyphosate, a widely-used 

herbicide with multiple uses, was included on this list of initial active ingredients to be 

tested because it met the exposure criteria. Test orders were issued for glyphosate in 

January of 2010, with a final submission due date of January 14, 2012.

Glyphosate has undergone extensive testing, including a battery of acute, sub-chronic, 

and chronic tests, and a number of developmental and reproductive studies, mammalian 

and wildlife, capable of detecting effects on endocrine mediated events. The results from 

these studies, along with other scientifically relevant information, provide reliable and 

functionally equivalent information to the Tier 1 screening assays and demonstrate that 

glyphosate is not an endocrine active substance.

9. Immunotoxicity. EPA recently instituted a new data requirement for an 

immunotoxicity study under 40 CFR Part 158 for all food and non-food use pesticides. 

The Agency does not currently have such a study for glyphosate. This data gap was 

identified in the Human-Health Assessment Scoping Document in Support of 

Registration Review for glyphosate which began in June 2009, not because of any 

concern that glyphosate may be a toxicant to the immune system, but because of the new

data requirement. A task force of glyphosate technical registrants in the U.S. is being 

assembled to address this issue under the Registration Review process. However, in lieu 

of any new data, the available glyphosate studies already provide a reasonable certainty 

that glyphosate is not immunotoxic.

C. Aggregate Exposure

Aggregate exposure for glyphosate is the combination of chronic dietary exposure (food 

+ drinking water) and short- and intermediate-term non-dietary oral exposure from 

residential (home lawn care) and recreational (golf, swimming) use exposure.

1. Dietary exposure. Tolerances have been established

(40CFR 180.364) for the residues of glyphosate N-(phosphonomethyl) glycine resulting 

from the application of glyphosate, the isopropylamine salt of glyphosate, the 

ethanolamine salt of glyphosate, the dimethylamine salt of glyphosate, the ammonium 

salt of glyphosate, and the potassium salt of glyphosate in or on a variety of raw 

agricultural commodities, including meat and meat by-products. The dietary-exposure 

database is adequate to support the existing registrations. Chronic dietary risk 

assessments incorporate concentration estimates from the direct application of glyphosate 

to water, which represents a worst-case scenario, as the drinking water component of the 

assessment.

The petitioner proposes to establish a tolerance for corn, field, forage at 13 ppm. The 

proposed tolerance revision is not expected to increase the dietary burden for livestock;

the existing tolerances for livestock commodities are sufficient.]

i. Food. No toxicological endpoint attributable to a single does of glyphosate has 

been identified; therefore, a quantitative acute dietary exposure assessment is not 

necessary. 
8

A dietary risk assessment was conducted by Monsanto using the Dietary Exposure 

Evaluation Model software (DEEM-FCIDTM), Version 2.16, which incorporates food 

consumption data from the United States Department of Agriculture (USDA) 1994-1996 

and 1998 Nationwide Continuing Surveys of Food Intakes by Individuals (CSFII). A

conservative estimate of dietary exposure (Tier 1) was performed with the assumptions 

that 100% of crops with approved and proposed uses of glyphosate would be treated and

that glyphosate residues would be present in each raw agricultural commodity at the 

tolerance level. Under these conservative assumptions and based on a chronic population 

adjusted dose (cPAD) for glyphosate of 1.75 mg/kg/day, the chronic dietary exposure 

estimates to glyphosate from food and drinking water is 5% of the cPAD for the general 

U.S. population. The chronic dietary exposure estimate for the most highly exposed 

subpopulation (children 1-2 years old) is 12% of the cPAD. 

Glyphosate is classified as a not likely human carcinogen, so a cancer dietary exposure 

analysis was not performed.

ii. Drinking water. The Agency lacks sufficient monitoring exposure data to 

complete a comprehensive dietary exposure analysis and risk assessment for glyphosate 

in drinking water. Because the Agency does not have comprehensive monitoring data, 

drinking water concentration estimates are made by reliance on simulation or modeling 

taking into account data on the physical characteristics of glyphosate. Further 

information regarding EPA drinking water models used in pesticide exposure assessment 

can be found at http://www.epa.gov/oppefed1/models/index.htm.

Glyphosate is registered for aquatic use to control weeds in bodies of water. Therefore, 

the Agency estimated the concentration in surface water resulting from direct application 

of the maximum single application rate of 3.75 pounds of glyphosate free acid per acre to 

a water body 6 feet deep. Based on this maximum application rate, the estimated 

concentration for use in the drinking water assessment is 230 g/L (ppb). This estimate is 

based on a dilution model that does not take into account degradation in the water body 

and partitioning into the water column-sediment phases. 

Based on the generic expected environmental concentration (GENEEC) and screening 

concentration in groundwater (SCI-GROW) models, the estimated environmental 

concentrations (EEC’s) of glyphosate for acute exposures are estimated to be 21 ppb for 

surface water and 0.0038 ppb for ground water. The EEC’s for chronic exposures are 

estimated to be 0.83 ppb for surface water and 0.0038 ppb for ground water, based on 

glyphosate treatment in crops.

2. Non-dietary exposure. Glyphosate is registered for broadcast and spot 

treatments on home lawns and gardens, including for turf renovation. Glyphosate 

products for homeowner use are packaged as ready-to-mix formulations and ready-to-use 

sprayers and are very common in home and garden stores in the U.S. Glyphosate 

products are also used by lawn care operators (LCOs) for broadcast and spot treatment 

weed control programs on homeowner lawns. Glyphosate products are also registered for
9

weed control in recreational areas, including parks and golf courses, and for control of 

aquatic weeds in lakes, ponds and reservoirs. All recreational and residential exposures 

assessed do not exceed the Agency’s level of concern (MOEs <100).

The term “residential exposure,” as used here, refers to non-occupational non-dietary 

exposure (e.g., for lawn and garden weed control). A risk assessment was conducted 

using the following residential exposure assumptions: Based on the registered residential 

use patterns, there is a potential for short-term dermal and inhalation exposures to 

homeowners who apply products containing glyphosate (residential handlers). 

Additionally, based on the results of environmental fate studies, there is also a potential 

for short- and intermediate-term post-application dermal exposures by adults and toddlers 

and incidental ingestion exposures by toddlers. However, since short- and intermediateterm dermal and inhalation endpoints were not identified, no residential handler or postapplication dermal assessment is required. Post-application toddler assessment for 

incidental ingestion exposures was performed; risk estimates ranged from 7,230 to 

greater than 106. 

Based on the registered uses of glyphosate in recreational areas and for aquatic weed 

control, adult and child golfers are anticipated to have short-term, post-application dermal 

exposure at golf courses and swimmers (adults, children and toddlers) are anticipated to 

have short-term post-application dermal and incidental ingestion exposures. However, 

since HIARC did not select dermal endpoints, no post-application dermal assessment is 

necessary. Post-application incidental ingestion exposure assessment was performed for 

adult, children and toddler swimmers; risk estimates ranged from 7,610 to 35,500.

Spray drift is always a potential source of exposure to residents nearby to spraying 

operations, particularly with aerial application, but, to a lesser extent, could also be a 

potential source of exposure from the ground application method employed for 

glyphosate. The Agency has been working with the Spray Drift Task Force, EPA 

Regional Offices and State Lead Agencies for pesticide regulation and other parties to 

develop the best spray drift management practices. 

D. Cumulative Effects

Unlike other pesticides for which EPA has followed a cumulative risk approach based on 

a common mechanism of toxicity, EPA has not made a common mechanism of toxicity 

finding as to glyphosate and any other substances, and glyphosate does not appear to 

produce a toxic metabolite produced by other substances. For the purposes of this 

tolerance action, therefore, EPA has not assumed that glyphosate has a common 

mechanism of toxicity with other substances. For information regarding EPA’s efforts to 

determine which chemicals have a common mechanism of toxicity and to evaluate the 

cumulative effects of such chemicals, see the final rule for Bifenthrin Pesticide 

Tolerances (62 FR 62961, November 26, 1997).
10

E. Safety Determination

1. U.S. population. A chronic dietary risk assessment of glyphosate was recently 

conducted using the current and the proposed new and increased tolerances for sweet 

corn. The Tier 1 chronic dietary analysis for glyphosate is a conservative estimate of 

dietary exposure that uses tolerance level residues and 100% crop treated. No increase in 

exposure is expected due to the proposed change in the corn forage tolerance, to support 

the use of glyphosate in RHS seed corn production. Under this assumption, exposure to 

glyphosate from food and water will utilize only 5% of the chronic population adjusted 

dose (cPAD) for the general U.S. population. Based on its use pattern, chronic residential 

and recreational exposure to residues of glyphosate is not expected.

Based on the completeness and reliability of the toxicity data and the conservative 

exposure assessment, it can be concluded that there is a reasonable certainty that no harm 

will result to the general U.S. population from chronic aggregate exposure to glyphosate 

residues.

2. Infants and children. FFCDA Section 408 provides that EPA shall apply an 

additional tenfold margin of safety for infants and children in the case of threshold effects 

to account for prenatal and postnatal toxicity and the completeness of the database. EPA 

has previously evaluated the prenatal and postnatal sensitivity of glyphosate and the 

adequacy of the data base as indicated in the Reregistration Eligilibility Decision for 

glyphosate. There is no evidence of increased susceptibility in rats and rabbits to in utero 

and/or postnatal exposure to glyphosate. EPA has concluded that there is a complete 

toxicity data base for glyphosate and exposure data are complete or are estimated based 

on data that reasonably accounts for all potential exposures. EPA determined that the 10X 

safety factor to protect infants and children is not necessary as well as the FQPA. The 

use of generally high quality data, conservative models and/or assumptions in the

exposure assessment, provide adequate protection of infants and children.

Chronic dietary exposure to residues of current and proposed tolerances is estimated to 

utilize only 12% of the chronic population adjusted dose (cPAD) for children 1-2 years 

old, which is the population subgroup predicted to be most highly exposed.

Use of glyphosate on turf does present a potential short- and intermediate-term exposure 

for children 1-2 years old. The aggregate MOE for the total short- and intermediate-term 

food and residential aggregate exposure are greater than 100, and, therefore, does not 

exceed the Agency’s level of concern.

Based on the completeness and reliability of the toxicity data and the conservative 

exposure assessment, it can be concluded that there is a reasonable certainty that no harm 

will result to infants and children from chronic, short- and intermediate-term aggregate 

exposure to glyphosate residues.
11

F. International Tolerances

There are no International MRLs for corn forage, so this petition will not impact 

any International MRLs for glyphosate.